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Home My WebLink About20191330.tiffPo b\c P,eA Ae 418/1q COLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 11500 St PO Box 758 Greeley, CO 80632 March 27, 2019 Dear Sir or Madam: RECEIVED APR 0 2 2019 WELD COUNTY COMMISSIONERS On April 4, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Verdad Resources LLC - Arnold 02N -64W-24 Production Facility. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Ft Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, Co 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical fficer TP)$ L(Tr), PWClr'(ERICttIc c 4/2/lq 2019-1330 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Verdad Resources LLC - Arnold 02N -64W-24 Production Facility - Weld County Notice Period Begins: April 4, 2019 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Verdad Resources LLC Facility: Arnold 02N -64W-24 Production Facility Well production facility NESW Section 24 T2N R64W Weld County The proposed project or activity is as follows: New EftP well production facility in the ozone non - attainment area of Weld County. Permitted equipment are condensate tanks, loadout of condensate, and venting/flaring from heater -treaters during VRU downtime. Permit -exempt equipment is produced water tanks. APEN-exempt equipment is separator heaters, heater -treater heaters, and facility fugitive emissions. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permits 18WE1155, 18WE1157, and 18WE1158 have been filed with the Weld County Clerk's office. A copy of the draft permits and the Division's analyses are available on the Division's website at https://www.colorado.Qov/pacific/cdphe/air- permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Andy Gruel Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 COLORADO 1 I ,. elPut& HWUrb Environ t COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 18WE1155 Issuance: 1 Verdad Resources LLC Facility Name: Plant AIRS ID: Physical Location: County: Description: Arnold 02N -64W-24 Production Facility 123/A007 NESW Section 24 T2N R64W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Equipment Description Point Description Emissions Control TK01-14 001 Fourteen (14) 400 barrel fixed roof storage vessels used to ; store condensate Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify Page 1 of 9 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.Qov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) I. F.4. ) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO. VOC CO TK01-14 001 -- 1.3 34.3 5.8 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Page 2 of 9 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Facility Equipment ID AIRS Point Control Device Pollutants Controlled TK01-14 001 Enclosed Flare V0C and HAP PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit TK01-14 001 Condensate throughput 383250 barrels , The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. This source is subject to Regulation Number 7, Section XII. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) Page 3 of 9 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1,; 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING Et MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16) Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. Page 4 of 9 COLORADO Air Pollution Control Division Department of Public Heath B Ermronmert€ Dedicated to protecting and improving the health and environment of the people of Colorado ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NO), per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per yearor more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year whichever is less, above the level reported on the last APEN submitted to the Division. Whenever there is a change in the owner or operator of any facility, process, or activity; or Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. Page 5 of 9 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet, any express term or condition ofthe. Permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Andy Gruel, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Verdad Resources LLC. Page 6 of 9 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 001 Benzene 71432 2064 103 Toluene 108883 1392 70 Ethylbenzene 100414 168 8 Xylenes 1330207 370 18 n -Hexane 110543 24883 1244 2,2,4-Trimethylpentane 540841 164 8 Note: All non -criteria reportable pollutants in the table above with uncontrolled emiss'on rates above 250 pounds per year ( b/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 0.0065 0.0065 AP -42 Ch. 13-5 CO 0.0298 0.0298 VOC 3.5744 0.1787 EFtP TANK model based on a site - 71432 Benzene 0.0054 0.00027 Page 7 of 9 COLORADO Air Pollution Control Division Delowament of Public Health ET Environment Dedicated to protecting and improving the health and environment of the people of Colorado CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source specific pressurized liquid sample collected 10/4/18. 108883 Toluene 0.0036 0.00018 100414 Ethylbenzene 0.0004 0.00002 1330207 Xylene 0.0010 0.00005 110543 n -Hexane 0.0649 0.00325 540841 2,2,4-Trimethylpentane 0.0004 0.00002 Note: The controlled emissions factors for this point are based on a control efficiency of 95%. NOx and CO emission factors are based on a vapor heat content of 2456 Btu/scf and a vapor volume of 39.166 scf/bbl (both from E£tP TANK model.) 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, HAP (n -hexane) NANSR Synthetic Minor Source of: VOC MACT HH Area Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKk NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z Page 8 of 9 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 9 of 9 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 18WE1157 Issuance: 1 Verdad Resources LLC Facility Name: Plant AIRS ID: Physical Location: County: General Description: Arnold 02N -64W-24 Production Facility 123/A007 NESW Section 24 T2N R64W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Equipment Description Point Description Emissions Control TL001 003 Truck loadout of condensate by submerged fill using vapor balance system. Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result Page 1 of 8 COLORADO Air Pollution Control Division Department of Public Health El Environment Dedicated to protecting and improving the health and environment of the people of Colorado in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations. (Reference: Regulation Number 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO. VOC CO TL001 003 --- --- 2.3 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits for both criteria and hazardous air pollutants shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Page 2 of 8 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Facility Equipment ID AIRS Point Control Device Pollutants Controlled TL001 003 Enclosed Flare VOC and HAP PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation Number 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit TL001 003 Condensate loaded 383,250 barrels The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 8. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 9. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 10. This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill and emissions shall be controlled by a flare. (Reference: Regulation 3, Part B, III.D.2) 11. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. 12. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): Page 3 of 8 COLORADO Air Pollution Control Division Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado a. The owner or operator shall inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. b. All compartment hatches at the facility (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers shall be weighted and properly seated. d. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs shall be set to release at a pressure that will ensure flashing, working and breathing losses are not vented through the PRD under normal operating conditions. e. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. 13. For this controlled loading operation, the owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, IIID2): a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. OPERATING a MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, inorder to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your OEtM plan are subject to Division approval prior to implementation. (Reference: Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Page 4 of 8 COLORADO Air Pollution Control Division Department at Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Periodic Testing Requirements 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 18. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 19. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD Page 5 of 8 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 20. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 21. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 22. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit.If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 23. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Andy Gruel, P.E. Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Verdad Resources LLC. Page 6 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 003 Benzene 71432 157 8 n -Hexane 110543 1380 69 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 003: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source N0x 0.000143 0.000143 AP -42 Ch. 13-5 CO 0.000651 0.000651 V0C 0.236 0.0118 Condensate Loadout State Default Benzene 71432 0.00041 0.0000205 n -Hexane 110543 0.0036 0.00018 Note: N0x and CO emission factors are based on the vapor heat content of 2456 Btu/scf (from EEtP TANK model) and vapor rate of 37.41 scf/hr. Page 7 of 8 COLORADO Air Pollution Control Division Department of Public Health & Envi!onment Dedicated to protecting and improving the health and environment of the people of Colorado Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of 100%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -hexane NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 8 of 8 COLORADO Air Pollution Control Division Department of Public Heath Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 18WE1158 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Verdad Resources LLC Arnold 02N -64W-24 Production Facility 123/A007 NESW Section 24 T2N R64W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description HT-VENT01 004 Venting of produced gas from heater- treaters. Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify Page 1 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. Within one hundred and eighty days (180) after issuance of this permit, the operator shall install a flow meter to monitor and record volumetric flow rate of natural gas vented from each separator covered by this permit. Until the flow meter is installed, the operator shall monitor and record condensate produced through the separator during VRU downtime, and estimate the gas flow rate based on standard cubic feet (scf) per barrel (bbl) of 95.24 scf/bbl estimated in the permit application. 5. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO. VOC CO HT-VENT01 004 --- --- 1.3 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate Page 2 of 10 COLORADO Air Pollution Control Division Department of Public Health £r Environment Dedicated to protecting and improving the health and environment of the people of Colorado actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 8. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled HT-VENT01 004 Emissions from the heater -treaters are routed to an Enclosed Flare during Vapor Recovery Unit (VRU) downtime VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit HT-VENT01 004 Natural Gas Venting 0.88 MMscf Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 10. Upon installation of the flow meter, the owner or operator shall continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 11. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 13. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation Page 3 of 10 COLORADO Air Pollution Control Division Department of Public Heath & Environment Dedicated to protecting and improving the health and environment of the people of Colorado from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 14. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING £t MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation.(Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.17) 17. The owner/operator shall complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after issuance of this permit, of the natural gas vented from this emissions unit in order to verify the VOC content (weight fraction) of this emission stream. Results of the Analysis shall be used to calculate a site -specific emission factor for VOC (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis shall be submitted to the Division as part of the self -certification and must demonstrate the VOC emission factor established through the Analysis is less than or equal to, the emission factor submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If the VOC site -specific emission factor developed through this Analysis is greater than the emission factor submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this inaccuracy. Page 4 of 10 COLORADO Air Pollution Control Division Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, ,a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. Whenever there is a change in the owner or operator of any facility, process, or activity; or, • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 20. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 21. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. Page 5 of 10 COLORADO Air Pollution Control Division Department of Public Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado 22. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 23. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 24. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 25. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab intio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Andy Gruel, P.E. Permit Engineer Page 6 of 10 COLORADO Air Pollution Control Division Depa-tment of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit History Issuance Date Description Issuance 1 This Issuance Issued to Verdad Resources LLC. Page 7 of 10 COLORADO Air Pollution Control Division Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) HT-VENT01 004 Benzene 71432 127 6 Toluene 108883 88 4 Ethylbenzene 100414 8 0.4 Xylenes 1330207 23 1 n -Hexane 110543 838 42 2,2,4- Trimethylpentane 540841 0.4 0.02 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 8 of 10 COLORADO Air Pollution Control Division Department of Pubic Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: Point 004: CAS # Pollutant Uncontrolled Emission Factors (lb/MMscf) Controlled Emission Factors (lb/MMscf) Source NOx 135.966 135.966 AP -42 CO 619.845 619.845 AP -42 VOC 59090.9091 2954.5455 Extended gas analysis of a representative (non -site -specific) gas sample 3/1/2019. 71432 Benzene 144.1705 7.2085 108883 Toluene 100.4432 5.0222 100414 Ethylbenzene 8.9886 0.4494 1330207 Xylene 26.5795 1.3290 110543 n -Hexane 951.9091 47.5955 540841 2,2,4-collected Trimethylpentane 0.4091 0.0205 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. NOx and CO emission factors are based on a gas heat value of 1999.5 Btu/scf. 6) In accordance with C.R.S. 25-7-114,1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for, each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)=692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -hexane NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories Page 9 of 10 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 10 of 10 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Andy Gruel Package #: 389800 . Received Date: 11/1/1s, wholly revised 1/28/19; subsequent revision 3/11/19 Review Start Date: 2/12/2019 Section 01- Facility Information Company Name: VerdadResources LLC County AIRS ID: 123 Plant AIRS ID: Facility Name: Physical Address/Location: County: Type of Facility: What industry segment? O Na al A Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ❑ Carbon Monoxide (CO) Arnold 02N -64W-24 Production Facility, NESW quadrant of Section 24, Township 2N, Range 64W Weld County Section 02 - Emissions Units In Permit Application Quadrant Section Township Range NESW 2N 64 Particulate Matter (PM) Ozone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Seff Cert Required? Action Engineering Remarks TK01-06,- PW01-04 18WE1155 tia CPS 002 18WE1156,XP P"e`emitE 5re TLOU1. W E11s7 CP.1 CP1 004 005 HT-UENTd1 18WE1158 Yes ?ai IssiJance VtENG01 GP02';� General Perrin€t; Pkg.384023 Section 03 - Description of Project New E&P Welt production facility in the ozone port-attai treater heaters, add facility fugitive emissions • Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? n•" entarea of Weld County. APEN-exempt equipment associated re separator heaters, heate Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? If yes, for what pollutants? y a If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Is this stationary source a major source? If yes, explain what programs and which pollutants herr 502 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) NOx CO VOC 0 C PM2.5 PM10 TSP HAPs El El Separator Venting Emissions Inventory 004 Separator Venting Facility AIRs ID: 123" County A007 ;- Plant 004 ',- Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency%: Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates heater -gas to enclosed comb,Tistor during vRU co0spressordowntime.: GCO ECD2000( 95 Requested Permit Limit Throughput Potential to Emit (PTE) Throughput = 0.88:: MMscf per year 0.88 MMscf per year Requested Monthly Throughput = 0 MMscf per month Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare( n Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL of 'd liquids throughput: Section 04 - Emissions Factors & Methodologies 1999.1 Btu/scf scf/bbl licant presented a representative (dot-sne-specific] separator gas sample collected 3/1/19. Asite-specific sample will be required- -:I calculated slight) I will accept those presented by the applicant. Vent r t estimated based on initial production data. Applicant states that a meter will be installed. ?. MW 35.2037) lb/Ib-mol Weight % Helium CO2 N2 methane ethane 0.000 _.. -,'`15.735 4 propane isobutane n -butane isopentane n -pentane cyclopentane n -Hexane cyclohexane Other hexanes heptanes methylcyclohexane 224-TMP Benzene Toluene Ethylbenzene Xylenes C8+ Heavies 30.842 5.110 15.104 15 4.172 0:272 .877 lil 0659 .260 0.0004 56 15.109 0.010 0.029 0.503 99.96 63.99 Total VOC Wt Displacement Equation ES=Q0 MW*Xx/C Emission Factors Separator Venting Pollutant Uncontrolled Controlled (lb/MMscf) (lb/MMscf) (Gas Throughput) (Gas Throughput) Emission Factor Source VOC 59090.9091 2954.5455 Benzene Toluene 144.1705 100.4432 7.2085 5.0222 0.4494 1.3290 47.5955 0.0205 Ethylbenzene 8.9886 26.5795 951.9091 Xylene n -Hexane 224 TMP 0.4091 Pollutant Primary Control Device Uncontrolled Uncontrolled (Ib/MMBtu) lb/MMscf (Waste Heat Combusted) (Gas Throughput) Emission Factor Source PM10 PM2.5 0.0075 0,0075 0.0006 0.0680_... 0.3100 14.898 14.898 1.176 500 NOx CO 135.966 619.845 2 of 6 K:\PA\2018\18 W E1158. CP 1 Separator Venting Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 PM2.5 SOx NOx VOC CO 0.01 0.01 0.01 0.01 0.01 1 0.01 0.01 0.01 0.01 0.01 - 1 0.00 0.00 0.00 0,00 0.00 0 0,06 0.05 0.05 0.06 0.06 10 26.00 21.57 1.08 26.00 1.30 221 0.27 0:23 0.23 0.27 0.27 46 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 127 105 5 127 6 88 73 4 88 4 8 7 0 8 0.4 23 19 1 23 1 838 695 35 838 42 0 0 0 0.4 0.02 Section 06- Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII.B, G Regulation 7, Section XVII.B.2.e (See regulatory applicabilityworksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Source requires a permit Source is subject to Regulation 7, Section XVII.B.2, G The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e Does the company use site specific emission factors based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRS ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. ItH �lik too,the permit will contain an "Initial Testing; Requiremenf to collect a site speck gas sample from the equipment being permitted and conduct an emission factor j n ysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year? If yes, the permit will contain: - -An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors ane less than or equal to the emissions factors established with this application. -A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors ale less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? No If no, the permit will contain a condition that requires the operator to calculate gas throughput using the Squid throughput until the meter is installed and operational (not to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling You have indicated above that the monitored process er is natural gas vented. The following questions do not require an answe 3 of 6 K:\PA\2018\18WE1158.CP1 Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes Site-specificgas sample is required. AIRS Point # 004 Section 09 - Inventory SCC Coding and Emissions Factors Process # SCC Code 01 3.10-001-60 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM10 14.90 0 lb/MMSCF PM2.5 14.90 0 Ib/MMSCF 100 1.18 0 lb/MMSCF NOx 135.97 0 lb/MMSCF VOC 59090.91 95 lb/MMSCF CO 619.85 0 lb/MMSCF Benzene 144.17 95 Ib/MMSCF Toluene 100.44 95 Ib/MMSCF Ethylbenzene 8.99 95 lb/MMSCF Xylene 26.58 95 lb/MMSCF n -Hexane 951.91 95 Ib/MMSCF 224 TMP 0.41 95 lb/MMSCF 4 of 6 K:\PA\2018\18WE1158.CP1 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name Verdad Resources LLC 123 A007 Arnold 02N -64W-24 Production Facility History File Edit Date Ozone Status 3/11/2019 Non -Attainment EMISSIONS - Uncontrolled (tons per year EMISSIONS With C POIN T AIRS PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facility total 0,0 0.0 0.0 0.0 0.0 0.0 0.0 0,0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 18WE1155 Condensate Tanks (5600 bbl) 0.1 0.1 1.3 684.9 5.8 14.5 0.1 0.1 1.3 34.3 5.8 0.7 SSEFs accepted 002 18WE1156.X Prod water tanks (1600 bbl) 0.1 0.1 0.5 37.3 2.4 4.1 0.1 0.1 0.5 1.9 2.4 0.2 State default Efs; 1% crude exemption 003 18WE1157 Condensate loadout to trucks 0.0 0.0 0.0 45.2 0.1 0.8 0.0 0.0 0.0 2.3 0.1 0.0 State default EFs 004 18WE1158 Heater -treater venting when VRU is down 0.0 0.0 0.1 26.0 0.3 0.5 0.0 0.0 0.1 1.3 0.3 0.0 SSEFs accepted 005 GP02 GM Vortec 5.7L, sn: 1 0CHMM501210037 0.1 0.1 12.4 0.6 9.8 0.1 0.1 0.1 0.9 0.6 1.8 0.1 New GP02 approved APEN-Exempt / Insignificants Separator heaters 0.2 0.2 0.1 2.2 0.1 1.8 0.0 0,2 0.2 0.1 2.2 0.1 1.8 0.0 From March 11 2019 Form 102 Heater -treater heaters 0.2 0.2 0.1 2.2 0.1 1.8 0.0 0.2 0.2 0.1 2.2 0.1 1.8 0.0 From March 11 2019 Form 102 Fugitives 0.3 0.0 0.3 0.0 From March 11 2019 Form 102 FACILITY TOTAL 0.6 0.6 0.0 0.3 18.6 794.3 0.3 21.9 20.1 0.6 0.6 0.0 0.3 7.1 40.5 0.3 13.9 1.1 VOC: Syn Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Minor (PSD and OP) HAPS: Syn Minor n -hexane 7777: Syn Minor Permitted Facility Total 0.2 0.2 0.0 0.0 13.8 756.8 0.0 15.9 15.9 0.2 0.2 0.0 0.0 2.2 38.4 0.0 7.9 0.9 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 0.2 0,2 0.0 0.0 2.2 38.4 0.0 7.9 Pubcom required based on new NANSR syn minor limits, and VOC increase Note 1 Total VOC Faci ity Emissions (point and fugitive (4) Change in Total Permitted VOC emissions (point and fugitive 40.8 Facility is eligible for GP02 because < 90 tpy Project emissions less than 25/50 tpy 38.4 Nov 2018 application had wholesale revisions made in January 2019 after new wells were drilled. APEN for point 004 was revised in March 2019. Note 2 Page 5 of 6 Printed 3/27/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Verdad Resources LLC County AIRS ID 123 Plant AIRS ID A007 Facility Name Arnold 02N -64W-24 Production Facility Emissions - uncontrolled (lbs per year POIN-PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpY) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 18WE1155 Condensate Tanks (5600 bbl) 2064 1392 168 370 24883 164 14.5 002 18WE1156.XP Prod water tanks (1600 bbl) 1993 6263 4.1 003 18WE1157 Condensate loadout to trucks 157 1380 0.8 004 18WE1158 Heater -treater venting when VRU is down 127 88 8 23 838 1 0.5 005 GP02 GM Vortec 5.7L, sn: 10CHMM501 149 20 19 11 22 0.1 APEN-Exempt / Insignificants Separator heaters 0.0 Heater -treater heaters 0.0 Fugitives 1 1 0 0 8 0.0 TOTAL (tpy) 0.1 0.0 0.0 2.2 0.7 0.1 0.2 16.7 0.0 0.1 0.0 0.0 20.1 "Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (Ibs per year POIN- PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tPY) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 18WE1155 Condensate Tanks (5600 bbl) 103 70 8 18 1244 8 0.7 002 18WE1156.XP Prod water tanks (1600 bbl) 100 313 0.2 003 18WE1157 Condensate loadout to trucks 8 69 • 0.0 004 18WE1158 Heater -treater venting when VRU is down 6 4 1 1 42 0.0 005 GP02 GM Vortec 5.7L, sn: 1 OCHMM501 149 20 19 11 22 0.1 APEN-Exempt / Insignificants Separator heaters 0.0 Heater -treater heaters 0.0 Fugitives 1 1 0 0 8 0.0 TOTAL (tpy) 0.1 0.0 0.0 0.1 0.0 0.0 0.0 0.8 0.0 0.0 0.0 0.0 1.1 6 18WE1158.CP1 3/27/2019 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Andy Gruel Package It 389800 Received Date: 11/1/18, wholly revised 1/28/19; subsequent revision 3/11/19 Review Start Date: 2/12/2019 Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: NESW quadrant of Section 24, Township 2N, Range 64W County: (Weld County Type of Facility: What industry segment? Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? El Carbon Monoxide (CO) Verdad Resources LLC 123 A007 Arnold 02N -644W-24 Production Facility Section 02 - Emissions Units In Permit Application Particulate Matter (PM) Quadrant I Section Township Range NESW 24 {" 2N' Ozone (NOx & VOC) AIRs Point 9 Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 Condensate Tess TK0106 Yes "18WE1155 CP1 Yes Permitlnitt/ l 002 '�", - Produced Water Tank '.,PW01 04 18WE1156 XP 1 CP1 Yes PermitExempt 003 Liquid Loading TL001 Yes 18WE1157 CPI -:'Yes Initial Issuance 004 Separator Ventutg HT-VENT01 Yes 18WE"158 " CP1 Yes Inital Issuance 005 0a ticai Gas AiCF V ENGOS GP02 General Pe mit Pkg 38.1023 Section 03 - Description of Project New E&P well production facility in the ozone non attainment area of Weld County. A.PEN-exempt equipment associated with this project are separator heaters, heater - treater heaters, and facility fugitive emissions. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? r° r If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits loP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, explain what programs and which pollutants here SO2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) NOx PM2.5 PM10 TSP HAPs D CO VOC PM2.5 PM10 TSP HAPs ❑ ❑ Condensate Storage Tank(s) Emissions Inventory 001 Condensate Tank 'Facility AIRs ID: County Plant Point Section 02- Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Enclosed Combustors (lx GC0 ECD2000) Requested Overall VOC & HAP Control Efficiency%: Section 03 -Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = Requested Permit Limit Throughput = urassouskj Barrels (bbl) per year 9 00. Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating = Requested Monthly Throughput= 32550 Barrels (bbl) per month Potential to Emit (PTE) Condensate Throughput 3,250' Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per BBL of liqui produced = Pilot gas use Pilot gas heat value Actual heat content of waste gas and pilot gas= Requested heat content of waste gas and pilot gas = Potential to Emit (PTE) heat content of waste gas and pilot gas = Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Btu/scf from E&P TANK model scf/bbl scf/hr Btu/scf from E&P TANK model 31,100 MMBTU per year 37,244 MMBTU per year 37,244 MMBTU per year Pollutant Pollutant NIMAIEW r r Uncontrolled Controlled (lb/bbl) (lb/bbl) (Condensate Throughput) 0.0054 0.0036 0.0004 00010 0.0649:.:: E0004;E'i: (Condensate Throughput) 0.00027 0.00018 0.00002 0.00005 0.00002 Control Device Uncontrolled (Ib/MMBtu( (waste heat combusted) Uncontrolled (Ib/bbl) 8.0075 0.0075 0.0680 (Condensate Throughput) 0.0007 0.0007 0.0065 0.0298 Emission Factor Source Emission Factor Source Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tans/year) Requested Monthly Limits Controlled (lbs/month) VOC PM10 PM2.5 NOx CO 684.9 570.8 28.5 684.94 34.25 5817 0.1 0.1 0.1 0.14 0.14 24 0.1 0.1 0.1 0.14 0.14 24 1.3 1.1 1.1 1.27 1.27 215 5.8 4.8 4.8 5.77 5.77 981 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 2064 1720 86 2064 103 1392 1160 58 1392 70 168 140 7 168 8 370 308 15 370 18 24883 20736 1037 24883 1244 164 136 7 164 8 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XII.C, D, E, F Storage tank is subject to Regulation 7, Section XII.C-F Regulation 7, Section XII.G, C Storage Tank is not subject to Regulation 7, Section XII.G Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.Z Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000 Regulation S, Part E, MACT Subpart HH Storage Tank is not subject to MAR NH Barrels (bbl) per year 2 of 7 K:\PA\2018\18W E1155.CP1 Condensate Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements - Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company use a site specific emissions factor to estimate emissions? If yes and If there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e., no new wells brought on-line), then it maybe appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 -Technical Analysis Notes Applicant used E&P TANK based on a. site -specific pressurized liquid. sample (collected 10/4/18) to model flash/working/breathing emissions. Section 09- Inventory SCC Coding and Emissions Factors AIRS Point # Process # SCC Code 001 01 ..... Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.02 0 lb/1,000 gallons condensate throughput PM2.5 0.02 0 lb/1,000 gallons condensate throughput NOx 0.16 0 lb/1,000 gallons condensate throughput VOC 85.1 95 lb/1,000 gallons condensate throughput CO 0.72 0 lb/1,000 gallons condensate throughput Benzene 0.13 95 lb/1,000 gallons condensate throughput Toluene 0.09 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.01 95 .1b/1,000 gallons condensate throughput Xylene 0.02 95 lb/1,000 gallons condensate throughput n -Hexane 1.55 95 lb/1,000 gallons condensate throughput 224 TMP 0.01 95 lb/1,000 gallons condensate throughput 4 of 7 K:\PA\2018\18W E1155.CP1 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name Verdad Resources LLC 123 A007 Arnold 02N -64W-24 Production Facility History File Edit Date Ozone Status 3/11/2019 Non -Attainment EMISSIONS - Uncontrolled (tons per year EMISSIONS WI POIN T AIRS PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 18WE1155 Condensate Tanks (5600 bbl) 0.1 0.1 1.3 684.9 5.8 14.5 0.1 0.1 1.3 34.3 5.8 0.7 SSEFs accepted 002 18WE1156.X Prod water tanks (1600 bbl) 0.1 0.1 0.5 37.3 2.4 4.1 0.1 0.1 0.5 1.9 2.4 0.2 State default Efs; 1% crude exemption 003 18WE1157 Condensate loadout to trucks 0.0 0.0 0.0 45.2 0.1 0.8 0.0 0.0 0.0 2.3 0.1 0.0 State default EFs 004 18WE1158 Heater -treater venting when VRU is down 0.0 0.0 0.1 26.0 0.3 0.5 0.0 0.0 0.1 1.3 0.3 0.0 SSEFs accepted 005 GP02 GM Vortec 5.7L, sn: 10CHMM501210037 0.1 0.1 12.4 0.6 9.8 0.1 0.1 0.1 0.9 0.6 1.8 0.1 New GP02 approved pp APEN-Exempt / Insignificants Separator heaters 0.2 0.2 0.1 2.2 0.1 1.8 0.0 0.2 0.2 0.1 2.2 0.1 1.8 0,0 From March 11 2019 Form 102 Heater -treater heaters 0.2 0.2 0.1 2.2 0.1 1.8 0.0 0.2 0.2 0.1 2.2 0.1 1.8 0.0 From March 11 2019 Form 102 Fugitives 0.3 0.0 0.3 0.0 From March 11 2019 Form 102 FACILITY TOTAL 0.6 0.6 0.0 0.3 18.6 794.3 0.3 21.9 20.1 0.6 0.6 0.0 0.3 7.1 40.5 0.3 13.9 1.1 VOC: Syn Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Minor (PSD and OP) HAPS: Syn Minor n -hexane ZZZZ: Syn Minor Permitted Facility Total 0.2 0.2 0.0 0.0 13.8 756.8 0.0 15.9 15.9 0.2 0.2 0.0 0.0 2.2 38.4 0.0 7.9 0.9 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 0.2 0.2 0.0 0.0 2.2 38.4 0.0 7.9 Pubcom required based on new NANSR syn minor limits, and VOC increase Note 1 Total VOC Faci ity Emissions (point and fugitive' (A) Change in Total Permitted VOC emissions (point and fugitive 40.8 Facility is eligible for GP02 because < 90 tpy Project emissions less than 25/50 tpy 38.4 Nov 2018 application had wholesale revisions made in January 2019 after new wells were drilled. APEN for point 004 was revised in March 2019. Note 2 Page 5of7 Printed 3/19/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name County AIRS ID Plant AIRS ID Facility Name Verdad Resources LLC 123 A007 Arnold 02N -64W-24 Production Facility Emissions - uncontrolled (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpY) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 18WE1155 Condensate Tanks (5600 bbl) 2064 1392 168 370 24883 164 14.5 002 18WE1156.XP Prod water tanks (1600 bbl) 1993 6263 4.1 003 18WE1157 Condensate loadout to trucks 157 1380 0.8 004 18WE1158 Heater -treater venting when VRU is down 127 88 8 23 838 1 0.5 005 GP02 GM Vortec 5.7L, sn: 10CHMM501 149 20 19 11 22 0.1 APEN-Exempt / Insignificants Separator heaters 0.0 Heater -treater heaters 0.0 Fugitives 1 1 0 0 8 0.0 TOTAL (tpy) 0.1 0.0 0.0 2.2 0.7 0.1 0.2 16.7 0.0 0.1 0.0 10.0 20.1 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (Ibs er year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpY) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 18WE1155 Condensate Tanks (5600 bbl) 103 70 8 18 1244 8 0.7 002 18WE1156.XP Prod water tanks (1600 bbl) 100 313 0.2 003 18WE1157 Condensate loadout to trucks 8 69 0.0 004 18WE1158 Heater -treater venting when VRU is down 6 4 1 1 42 0.0 005 GP02 GM Vortec 5.7L, sn: 10CHMM501 149 20 19 11 22 0.1 APEN-Exempt / Insignificants (Separator heaters 0.0 6 18WE1155.CP1 3/19/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name County AIRS ID Plant AIRS ID Facility Name Verdad Resources LLC 123 A007 Arnold 02N -64W-24 Production Facility Heater -treater heaters 0.0 Fugitives 1 1 0 0 8 0.0 TOTAL (tpy) 0.1 0.0 0.0 0.1 0.0 0.0 0.0 0.8 0.0 0.0 0.0 0.0 1.1 7 18WE1155.CP1 3/19/2019 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Andy Gruel . 189800 11/1/18, wholly revised 1/28/19; subsequent revision 3/11/19 2/12/2019 Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: County: Type of Facility: Eltp What industry segment? YOKE Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ❑ carbon Monoxide (co) Veerdad' {e'sources LLG 123 A007 t Arpold 02N -64W-24 Production Facility N€5W quadrant of Section 24, Township 2N, Range 64W 'Weld County h Section 02 - Emissions Units In Permit Application P Emissions Control? Quadrant Section Township Range NESW 24 N 64 Particulate Matter (PM) E Ozone (NOx & VOC) AIRs Point 6 Emissions Source Type Equipment Name Permit It Issuance # Self Cert Required? Action Engineering Remarks 001 002 -' s0 :,TK01-06r 8WE1155 CP1 CP1 peiptltjistttalas= Pwrmttag Pr€ ducod w. PW01 04 18WE11S6.XP 9`18WE1157 & 3 _. LiquIed Loadiin"g , ii?i TLOO1 'r t otipg .s HT VENT01 18W E1158 CP1 II aoe 84023 `` 005 r- --_=I�latul Ga'`s:PiCS V-ENG01 GP02 -General Permit; P 3I Section 03 - Description of Project New E&P well prpd_uction facilityin theozone non -a' E treater heaters, and facility fugitive emissions ate Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? pment ace Weld County. AP -EN -exempt equipment associated ,with this;projectareseparatorhea"ters,heate Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, explain what programs and which pollutants here SO2 NOx Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NAN5R) 502 NOx CO VOC PM2.5 PM10 TSP HAPs CO VOC ❑ ❑� PM2.5 PM10 TSP HAPs ❑ ❑ Hydrocarbon Loadout Emissions Inventory 003 Liquid Loading IFacility AIRs ID: 123 County Section 02 -Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Is this loadout controlled? Collection Efficiency: Control Efficiency: Loadout of condensate to tank trucks Enclosed Combustors (2x GC0 ECD20 Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = Requested Permit Limit Throughput = i $3J250 Barrels (bbl) per year Requested Monthly Throughput= 32550 Barrels (bbl) per month Potential to Emit (PTE) Volume Loaded = 5007 s. is 003 Plant Po nt 95.00 Barrels (bbl) per year Jan Actual Volume Loaded While Emissions Controls Operating= {Igr 9si ` Sa Barrels (bbl) per year Secondary Emissions -Combustion Device(s) Heat content of waste gas= n Y Estimated vapor rate= .> Volume of waste gas emitted per year = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 37 Barrels (bbl) per year Btu/scf X37 &21 scf/hr 327712 scf/year Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04- Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Does the hydrocarbon liquid loading operation utilize submerged fill? Pollutant Uncontrolled Controlled (Ib/bblj (lb/bbl) (Volume Loaded) (Volume Loaded) Emission Factors Hydrocarbon Loadout from E&P TANK model assumed by applicant 671 MMBTU per year 805 MMBTU per year 805 MMBTU per year The state default emissions factors may be used to estimate emissions. Emission Factor Source gAyari VOC 0.236 0.0115 Benzene Toluene 0.00041 0.0000205 Ethylbenzene Xylene n -Hexane 224 TMP 0.0036 0.00018 Emission Factor Source Pollutant Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (Ib/bbl) (waste heat combusted) (Volume Loaded) 1.56E-05 1.56E-05 1.24E-06 1.43E-04 6.51E-04 PM10 PM2.5 0.0075 0.0075 0.0006' 0.0680 0.3100 500 NOx CO 2 of6 K:\PA\2018\18W E1157.CP1 Hydrocarbon Loadout Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled .(tens/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) PM10 PM2.5 sox NOx VOC CO 0.00 0.00 0.00 0.003 0.003 1 0.00 0.00 0.00 0.003 0.003 1 0.00 0.00 0.00 0.0002 0.0002 0 0.03 0.02 , 0.02 I 0,03 0,03 5 45.22 37.69 1.88 45.22 2.26 384 0.12 0.10 0.1,0 0.12 .0.12 21 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 157 131 7 157 8 1380 1150 57 1380 69 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit RACT- Regulation 3, Part B, Section III.D.2.a (See regulatory applicability worksheet for detailed analysis) The loadout must operate with submerged fill and loadout emissions must be routed to flare to satisfy RACT. Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 -Technical Anal nis Notes Section 09- Inventory 5CC Coding and Emissions Factors AIRS Point# Process # 5CC Code 003 01 4.06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6) Uncontrolled Emissions Pollutant Factor Control% Units PM10 0.0004 0 lb/1,000 gallons transferred PM2.5 0.0004 0 lb/1,000 gallons transferred SOx 0.00 0 lb/1,000 gallons transferred NOx 0.0034 0 lb/1,000 gallons transferred VOC 5.6190 95 lb/1,000 gallons transferred CO 0.0155 0 lb/1,000 gallons transferred Benzene 0.0098 95 lb/1,000 gallons transferred n -Hexane 0.0857 95 lb/1,000 gallons transferred 3 of 6 K:\PA\2018\18WE1157.CP1 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name Verdad Resources LLC 123 A007 Arnold 02N -64W-24 Production Facility History File Edit Date Ozone Status 3/11/2019 Non -Attainment EMISSIONS - Uncontrolled (tons per year EMISSIONS With Controls (tons per year POIN T AIRS PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facility total 0.0 0.0 0,0 0.0 0.0 0.0 0.0 0.0 0,0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 18WE1155 Condensate Tanks (5600 bbl) 0.1 0.1 1.3 684.9 5.8 14.5 0.1 0.1 1.3 34.3 5.8 0.7 SSEFs accepted 002 18WE1156.X Prod water tanks (1600 bbl) 0.1 0.1 0.5 37.3 2.4 4.1 0.1 0.1 0.5 1.9 2.4 0.2 State default Efs; 1% crude exemption 003 18WE1157 Condensate loadout to trucks 0.0 0.0 0.0 45.2 0.1 0.8 0.0 0.0 0.0 2.3 0.1 0.0 State default EFs 004 18WE1158 Heater -treater venting when VRU is down 0.0 0.0 0.1 26.0 0.3 0.5 0.0 0.0 0.1 1.3 0.3 0.0 SSEFs accepted 005 GP02 GM Vortec 5.7L, sn: 10CHMM501210037 0.1 0.1 12.4 0.6 9.8 0.1 0.1 0.1 0.9 0.6 1.8 0.1 New GP02 approved APEN-Exempt / Insignificants Separator heaters 0.2 0.2 0.1 2.2 0.1 1.8 0.0 0.2 0.2 0.1 2.2 0.1 1.8 0.0 From March 11 2019 Form 102 Heater -treater heaters 0.2 0.2 0.1 2.2 0.1 1.8 0.0 0.2 0.2 0.1 2.2 0.1 1.8 0.0 From March 11 2019 Form 102 Fugitives 0.3 0.0 0.3 0.0 From March 11 2019 Form 102 FACILITY TOTAL 0.6 0.6 0.0 0.3 18.6 794.3 0.3 21.9 20.1 0.6 0.6 0.0 0.3 7.1 40.5 0.3 13.9 1.1 VOC: Syn Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Minor (PSD and OP) HAPS: Syn Minor n -hexane ZZZZ: Syn Minor Permitted Facility Total 0.2 0.2 0.0 0.0 13.8 756.8 0.0 15.9 15.9 0.2 0.2 0.0 0.0 2.2 38.4 0.0 7.9 0.9 Excludes units exempt from permits/APENs (0) Change in Permitted Emissions 0.2 0.2 0.0 0.0 2.2 38.4 0.0 7.9 Pubcom required based on new NANSR syn minor limits, and VOC increase Note 1 Total VOC Facility Emissions (point and fugitive' i A) Change in Total Permitted VOC emissions (point and fugitive 40.8 Facility is eligible for GP02 because < 90 tpy Project emissions less than 25/50 tpy 38.4 Nov 2018 application had wholesale revisions made in January 2019 after new wells were drilled. APEN for point 004 was revised in March 2019. Note 2 Page 4 of 6 Printed 3/19/2019 Company Name County AIRS ID Plant AIRS ID Facility Name COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Verdad Resources LLC 123 A007 Arnold 02N -64W-24 Production Facility Emissions - uncontrolled (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL NY) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 18WE1155 Condensate Tanks (5600 bbl) 2064 1392 168 370 24883 164 14.5 002 18WE1156.XP Prod water tanks (1600 bbl) 1993 6263 4.1 003 18WE1157 Condensate loadout to trucks 157 1380 0.8 004 18WE1158 Heater -treater venting when VRU is down 127 88 8 23 838 1 0.5 005 GP02 GM Vortec 5.7L, sn: 10CHMM501 149 20 19 11 22 0.1 APEN-Exempt / Insignificants Separator heaters 0.0 Heater -treater heaters 0.0 Fugitives 1 1 0 0 8 0.0 TOTAL (tpy) 0.1 0.0 0.0 2.2 0.7 0.1 0.2 16.7 0.0 0.1 0.0 0.0 20.1 otal Reportable=a Red Text: uncontrolled emissions < de minimus Emissions with controls (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL NY) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 18WE1155 Condensate Tanks (5600 bbl) 103 70 8 18 1244 8 0.7 002 18WE1156.XP Prod water tanks (1600 bbl) 100 313 0.2 003 18WE1157 Condensate loadout to trucks 8 69 0.0 004 18WE1158 Heater -treater venting when VRU is down 6 4 1 1 42 0.0 005 GP02 GM Vortec 5.7L, sn: 10CHMM501. 149 20 19 11 22 0.1 APEN-Exempt / Insignificants (Separator heaters 0.0 5 18WE1157.CP1 3/19/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Verdad Resources LLC County AIRS ID 123 Plant AIRS ID A007 Facility Name Arnold 02N -64W-24 Production Facility Heater -treater heaters 0.0 Fugitives 1 1 0 0 8 0.0 TOTAL (tpy) 0.1 0.0 0.0 0.1 0.0 0.0 0.0 0.8 0.0 0.0 0.0 0.0 1.1 6 18WE1157.CP1 3/19/2019 RECEIVED) 411428 2019 APCD Condensate Storage Tank(s) APEN Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at www calorada gov/pacifictcdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 18WE1155 AIRS ID Number: 123 / A007 / 001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Verdad Resources LLC Site Name: Arnold 02N -64W-24 Production Facility Site Location: NESW Sec 24 T2N R64W 40.120875/-104.500364 Mailing Address: (tndu ie Zip Code) 1401 17th Street, Suite 925 Denver, Colorado 80202 Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Phone Number: E -Mail Address2: Brad Ganong 720-845-6918 bganang@verdadoil.com I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-205 Condensate Storage Tank(s) APEN - Rev sion 07/20 g 9 4 COLORADO Permit Number: 18WE1155 AIRS ID Number: 123 / A007 / 001 [Leave blank unless APCD has already assigned a permit /land AIRS IDI Section 2 - Requested Action 0 NEW permit OR newly -reported emission source • Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name O Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit exempt/grandfathered source O Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Update to Initial Permit Application Update conducted to account for additional wells and process equipment not initially planned. 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Condensate Storage Tanks For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 hours/day 7 days/week 52 Storage tank(s) located at: 08/07/18 ❑✓ Exploration Et Production (E&P) site weeks/year El Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? I Yes No ■ Are Flash Emissions anticipated from these storage tanks? El Yes ■ No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? ■ Yes © No if "yes", identify the stock tank gas -to -oil ratio: 0.0050 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105:: Q s Yes No Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? 0 Yes Q No Form APCD-2O5 - Condensate Storage Tank(s) APEN - Revision 07/2017 21 •COLORADA Permit Number: 18WE 1155 AIRS ID Number: 123 / A007 / 001 [Leave blank unless APCD has already assiened a permit /1 and AIRS ID] Section 4 - Storage Tank(s) Information 1Condensate Throughput: Actual Annual Amount (bbllyear) 319,375 From what year is the actual annual amount? projected Average API gravity of sales oil: -40 degrees ❑ Internal floating roof Tank design: 0 Fixed roof Requested Annual Permit Limit4 (bollyear) t 383,250 RVP of sales oil: —8.5 ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage . Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) TK01-14 14 5600 02/2019 081201.8.. API Number 05 - 123 - 46822 Wells Serviced by this Storage..: Tank or Tank Battery5 (EEP Sites Only) Name of Well Helen 24-3H Newly Reported Well_. 05 - 123 - 46630 Helen 24-3H 05 - 123 - 46594 Boyd 24-1 H 05 - 123 - 46597 Boyd 24-3H 4 Requested values wilt become permit limitations. Requested limit(s) should consider future growth. 5 The EftP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to 'report all welts that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 4; 40.120875/-104.500364 Operator Stack ID No. Discharge Height Above . Ground Level (feet) Temp. (°F.) Flow Rate (ACFM). Velocity (ft/sec) EC01-EC02 20 1000 25 0.026 Indicate the direction of the stack outlet: (check one) • Upward ❑ Horizontal ❑ Downward ❑ Other (describe); Indicate the stack opening and size: (check one) Q Circular ❑ Square/rectangle ❑ Other (describe): Interior stack diameter (inches): O Upward with obstructing raincap 54 Interior stack width (inches): Interior stack depth (inches): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017 3 I Permit Number: 18WE1155 AIRS ID Number: 123 I A007 / 001 [Leave blank unless APO has already assigned a permit # and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor ❑ Recovery Unit (VRU):; Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): 1:-J Combustion Device: O Other: Pollutants Controlled: VOC/HAPs Rating: MMBtu/ hr Type: 2 x Enclosed Combustors Make/Model: 2x GCO ECD2000 Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: Description of the closed loop system: Pollutants Controlled: Description: Control Efficiency Requested: 2456 -0.043 Btu/scf MMBtu/hr Section 7 -Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? -26.0 psig Describe the separation process between the well and the storage tanks: produced fluids from the wells are directed to four 3 -phase horizontal heated separators. From the separators, oil is directed to four 3 -phase vertical heater treaters for further separation and pressure reduction, Form APCD-205 - Condensate Storage Tank(s) APEN • Revision 07/2017 cocQanpo 4 x VOC Permit Number: 18WE1155 AIRS ID Number: 123 / A007 / 001 Leave blank unless APCD has already assigned a permit « and AIRS ID] Section 8 - Emissions Inventory Information Attach alt emissions calculations and emission factor documentation to this APEN form6. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (a reduction) Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) Enclosed Combustor 55 NOx CO HAPs Enclosed Combustor 5 Other: From what year is the following reported actual annual emissions data? projected Pollutant _ voc NOx Criteria Pollutant Emissions Inventory Source (AP -42, Mfg. etc) Controlled Emissions? (Tons/year) Actual Annual Emissions Requested Annual Permit Emission Limit(s)4 Uncontrolled Basis 3.57.._ 0.0067 Units lb/bbl ib/bbl Site Specific Calculated Uncontrolled Emissions (Tons/year) Uncontrolled Emissions (Tons/year). 684.94 1.28 Controlled Emissions (Tons/year) 34.25 1,28 CO 0.030 lb/bbl Calculated 5.73 5.73 Chemical Name Benzene Toluene Non -Criteria Reportable Pollutant Emissions Inventory Chemical Abstract Service (CAS) Number 71432 .. _. 108883 Emission Factorb.. Actual Annual Emissions Uncontrolled Basis 0.0054 0.0036 Units lb/bbl lb/bbl Source (AP -42, Mfg. etc) Site Specific Site Specific. Uncontrolled Emissions. (Pounds/year) 1,720,00 1,160.00 Controlled Emissions': . (Pounds/year) 86.00 58.00 Ethytbenzene. Xylene 100414 1330207 0.0010 Ib/bbl Site Specific 308.00 15.40 n -Hexane 110543 0.065 Ib/bbl Site Specific, 20,73600 1,036.80 2,2,4- Trimethylpentane. 540841 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-205 - Condensate Storage Tank(s) APEN • Revision 07/2017 COLORADO 5 I v„�.p; NRYA Ah#M�2 3"/RC. Permit Number: 18WE1155 AIRS ID Number: 123 / A007 / 001 [Leave blank unless APCD has already assigned a permit # and MRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and wilt be operated in full compliance with each condition of the applicable General Permit. Signature of Legally Anti 4 zed Person (not a vendor or consultant) Michael Cugnetti Date EH&S Manager Name (print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit For more information or assistance call: registration fee of $250, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/aped COLORADO Form APCD-205 - Condensate Storage Tank(s) APEN: Revision 0712017 6 I 02/2017 tkckC RECEIVED ,lAti 2 8 2019 P<'D Hydrocarbon Liquid Loading APEN - Form APCD-2081'''' Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is fitted out incorrectly or is missing information and requires re -submittal. This APEN is to be used for Hydrocarbon Liquid Loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado gov/cdphe/aped. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 18WE1157 AIRS ID Number: 1231A007 /003 [Leave blank unless APCD has already assigned a permit !F and AIRS ID] Company equipment Identification: TL001 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization Section 1 - Administrative Information -- Company Name': - Verdad Resources LLC Site Name: Arnold 02N -64W-24 Production Facility Site Location: NESW Sec 24 T2N R84W 40.120875/-104.500364 Mailing Address: (Include Zip Code) 1401 17th Street, Suite 925 Denver Colorado 80202 E -Mail Address2: bganong@verdadoil.com Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Brad Ganong Phone Number: 720-845-6918 'Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issuedby the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Rev 206\, L C1zA8ADO Permit Number: 18WE1157 AIRS ID Number: 123 /A007 / 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action ❑✓ NEW permit OR newly -reported emission source ❑ Request coverage under construction permit D Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN Filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Change permit limit ❑ Transfer of ownership' 0 Other (describe below) OR - • APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info & Notes: APEN update to initial application. Update to account for additional wells and process equipment not initially planned.. iFor transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 .- General Information -- -- General description of equipment and purpose: Hydrocarbon Truck Loadout For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 08/ 07 /2018 Wilt this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Does this source load gasoline into transport vehicles? Is this source located at an oil and gas exploration and production site? If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Does this source splash fill less than 6750 BBL of condensate per year? Does this source submerge fill less than 16308 BBL of condensate per year? Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 1❑. Yes ❑ No Lij Yes. No ❑ Yes Q No 0 Yes 0 No ❑' Yes ❑ No Yes ❑ No Yes O' No AWN CCLORAD.^. 2 1 Permit Number: 18WE1157 AIRS ID Number: 123 /A007/ 003 [Leave blank unless APCD has already assigned a permit It and AIRS ID] Section 4 - Process Equipment Information Product Loaded: El Condensate ❑ Crude Oil O Other: if this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded4: 319,375 Bbl/yr Actual Volume Loaded: 383,250 Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth This product is loaded from tanks at this facility into: trucks (eg, "rail tank cars" or "tank trucks") If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: Average temperature of bulk liquid loading: p:F True Vapor Pressure Asia 60 'F Molecular weight of displaced vapors Lb/lb mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Actual Volume Loaded5: Loaded: 4 Requested values will become permit limitations. Requested lintit(s)'should consider future process growth Bbl/yr Bbl/yr Product Density: Lb/ft3 Load Line Volume: ft3/trucktoad Vapor Recovery Line Volume ft3/truckload Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 3 � _..,COiORA04 ;�.�, Permit Number: 18WE 1157 AIRS ID Number: 123/A007/ 003 [Leave blank unless APCD has already assigned a permit. It and AIRS ID] Section 5 - Geographical Information Geographical Coordinates (Latitude/Longitude or UTM) 40.120875/-104.500364 Operator Stack iii No Discharge Height � �� < � Above Ground Level W l� Y Fee}:. i Temp (" F � Flow Rate � 1G`�-A k{� [FM veIacity SEC� y1' EC01-02 20 1000 25 0.026 Indicate the direction of the stack outlet: (check one) ❑r Upward ❑ Horizontal ❑ Downward El Other (describe): Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): O Other (describe): ❑ Upward with obstructing raincap 54 Section 6 - Control Device Information Loading occurs using a vapor balance system: Requested Control Efficiency 95 % QCombustion Device: Pollutants Controlled: VOC, HAPS ................. . Rating:- Type: 2 x Enclosed Combustor Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: n/a MMBtu/hr Make/Model: 2 x GCO ECD2000 95 98 Waste Gas Heat Content 2456 Btu/scf Constant Pilot Light: C] Yes ❑ No Pilot burner Rating 0.043 MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 cvLORh7G. 4 I .a4 trgt; PM PM Permit Number: 18WE1157 AIRS ID Number: 123 /A007/ 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? 2 Yes 0 No If yes, describe the control equipment AND state the overall control efficiency (% reduction): Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions)...:.... x NOx CO VOC vapor balance 95 HAPs vapor balance 95 Other: 0 Using State Emission Factors (Required for GP07) VOC E Condensate ❑ Crude 0.236 Lbs/BBL 0.104 Lbs/BBL Benzene 0.00041 Lbs/BBL 0.00018 Lbs/BBL n -Hexane 0.0036 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? Projected Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Uncontrolled Emission Factor Emission Factor Units Emission Factor .. Source (AP -42, Mfg. etc) Uncontrolled Controlled' (Tons/year) (Tonslyear) equested Annual Permit Emission Limit(s)s Uncontrolled Controlled (ions/year}t'Tonstyear) SO, NOx 000034 lb/bbl Calculated 0.066 0,066 VOC 0.236 lb/bbl CDPHE 45.22 2.26 CO 0.0016 lb/bbl Calculated 0.30 0.30 Benzene 0.00041 lb/bbl CDPHE 0.079 0.0039 Toluene Ethylbenzene Xylenes n -Hexane 0.0036 lb/bbl CDPHE 0.69 0.034 2,2,4- Trimethylpentane Other: 4 Requested values wilt become permit limitations. Requested limit(s) should consider future process growth. 5Annuat emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 51` ccLO tD0 � &Y eub.�mwr3 Permit Number: 18WE1157 AIRS ID Number: 123/A007/003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. ",‘ //20 //1 Signature of L • :. thorized Person (not a vendor or consultant) Date Michael Cugnetti EH&S Manager Name (print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, B.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit registration fee of $250 as applicable to: Colorado Department of Public Health and Environment Mr Pollution Control Division APCD-SS-81 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 COLORADO 6 AY Natural Gas Venting APEN - Form APCD-211 kttk Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options wilt not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 18WE1158 AIRS ID Number: 123 /A007/ 004 [Leave blank unless APCD has already assigned a permit n and AIRS ID] Company equipment Identification: HT-VENTO1 [Provide_Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Verdad Resources LLC Site Name: Arnold 02N -64W-24 Production Facility Site Location: NESW Sec 24 T2N R64W 40.120875/-104.500364 Mailing Address: (Include Zip Code) 1401 17th Street, Suite 925 Denver, Colorado 80202 E -Mail Address2: bganong@verdadoil.com Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Brad Ganong Phone Number: 720-845-6918 'Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-211 - Natural Gas Venting APEN - Rev 03/2017 Fns -=1u ./W 1 Q". 3 gig COLORADO cewn....nt f r , Nes. b G.vsmwrNN Permit Number: 18WE 1158 AIRS ID Number: 123 /A007/ 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action ✓❑ NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership3 0 Other (describe below) -OR - ❑ APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info it Notes: APEN Update (red line) to Initial Permit Application 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: compressor downtime. Heater Treater venting during VRU For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 08 / 07 / 2018 / / 0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: variable hours/day variable days/week variable weeks/year Will this equipment be operated in any NAAQS nonattainment area Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions ❑✓ Yes ❑ Yes ❑ No ❑✓ No Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017 COLORADO 2 I ®®'[kpan n. olPpUc Hu th & Enriron,n :d Permit Number: 18WE1158 AIRS ID Number: 123 /A007/ 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information El Gas/Liquid Separator ❑ Well Head Casing O Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: Serial #: Capacity: Gal/min # of Pistons: Leak Rate: Scf/hr/pist O Blowdown Events # of Events/year: Volume per event: MMscf/event ▪ Other Description: During VRU compressor downtime, gas from the heater treaters is directed to the enclosed combustor. If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? O Yes Natural Gas Venting Process Parameters4: Liquid Throughput Process Parameters4: ❑✓ No Maximum Vent Rate: 4166.7 SCF/hr Vent Gas Heating Value: 1999.5 BTU/SCF Requested: 0.88 MMSCF/year Actual: 0.73 MMSCF/year -OR- Requested: Bbl/yr Actual: Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Process Properties: Molecular Weight: VOC (mole %) 42.68 VOC (Weight %) 63.99 Benzene (mole %) 0.0704 Benzene (Weight %) 0.1561 Toluene (mole %) 0.0416 Toluene (Weight %) 0.1088 Ethylbenzene (mole %) 0.0032 Ethylbenzene (Weight %) 0.0097 Xylene (mole %) 0.0095 Xylene (Weight %) 0.0288 n -Hexane (mole %) 0.4211 n -Hexane (Weight %) 1.0309 2,2,4-Trimethylpentane (mole %) 0.0001 2,2,4-Trimethylpentane (Weight %) 0.0004 Additional Required Information: ❑ Attach a representative gas analysis (including BTEX it n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX It n -Hexane, temperature, and pressure) O Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017 COLORADO 3 ► ��'°��fE..or: ,t.On sr,RA DO Permit Number: 18WE1158 AIRS ID Number: 123 /A007/ 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates, (Latitude/Longitude or UTM) 40.120875/-104.500364 Operator Stack ID No. Discharge Height'. Above Ground, Level - (Feet) Temp• (?F) Flow Rate (ACFM) . Velocity (it/sec) :,�a EC01-02 20 1000 25 0.026 Indicate the direction of the stack outlet: (check one) ❑✓ Upward O Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap 54 Section 6 - Control Device Information ❑ VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency % VRU Downtime or Bypassed ❑ Combustion Device: Pollutants Controlled: VOC/HAPs Rating: Type: 2 x Enclosed Combustor Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: N/A MMBtu/hr Make/Model: 2 x GCQ ECD2000 95 98 % % Waste Gas Heat Content 1999.5 Btu/scf Constant Pilot Light: p Yes O No Pilot burner Rating ---0.043 MMBtu/hr O Other: Pollutants Controlled: Description: Control Efficiency Requested 0 Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017 COLORADO Hats B [mYronmeN Permit Number: 18WE1158 AIRS ID Number: 123 /A007/ 004 /467 \w1 PM [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ['Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency (% reduction): Control. Equipment Description Overall Requested Control Efficiency (% reduction in, emissions) SOX NO„ VOC Enclosed Combustor 95 CO HAPs Enclosed Combustor 95 Other: From what year is the following reported actual annual emissions data? N/A Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Pollutant Uncontrolled Emission„,--.,-.,Factor::Source Factor- Emission Units Emission '_ Factor AP 42 Mfg. etc) Actual Annual Emissions Requested.Annual Emission1:imit Permit I Uncontrolled (Tons/yearj Controlled {Tons/year) Uncontrolled (Tons%yeaj Controlled _ (Tdoy _ j PM SOX NOX 0.068 lb/MMBtu AP -42 0.060 0.060 VOC Sq, oq --27Tr. lb/Mscf Site specific 26.00 1.30 CO 0.31 lb/MMBtu AP -42 0.27 0.27 Benzene o •19 _aA872 lb/Mscf Site specific 6.34E-02 3.17E-03 Toluene o -1 0 O,gg5CT lb/Mscf Site specific 4.42E-02 2.21 E-03 Ethylbenzene O.o I LOSID45- lb/Mscf Site specific 3.95E-03 1.98E-04 Xylenes 0,03 0-(2031 lb/Mscf Site specific 1.17E-02 - 5.85E-04 n -Hexane o -9 5L 0.048 lb/Mscf Site specific 4.19E-01 2.09E-02 2'2'4 el - --- Trimethylpentane t 0.000020 lb/Mscf Site specific 1.78E-04 8.91E-06 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017 5 I V �`p a cn a Tmtic iii x.an trcnvwn,a.n� COLORADO Permit Number: 18WE1158 AIRS ID Number: l_.eav,: b6;,r% ::mess APCD has .,.r_eady assiQnea ern -it 123 /A007/ 004 Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. Signat of Legally As Eiarized Person (not a vendor or consultant) Date Michael Cugnetti EH&S Manager Name (please print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with $152.90 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692.3150 Form ,P ,�> (; s Venting APENRev i t20: APCD-211 td:,ur:E ...� - �).: ��1,' For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https: //www.colorado.govicdphe/apcd .COLORADO wr+nn:aro of wi.m Hee;fh5 �:1V,:vi:tltl:l Hello